Performing the PPE Hazard Analysis
Select PPE only after the first four options in the hierarchy of controls have been evaluated and found to be infeasible.
THOUSANDS of people are blinded each year from work-related eye injuries that could have been prevented with the proper selection and use of eye and face protection. Eye injuries alone cost more than $300 million per year in lost production time, medical expenses, and worker's compensation. (Source: Occupational Safety and Health Administration).
Failure to adequately assess the workplace for potential hazards and identify appropriate personal protective equipment (PPE) not only results in thousands of eye injuries each year; it is also responsible for numerous injuries to the hands and arms, torso, feet, and head.
PPE Hazard Assessment
To ensure employees wear appropriate PPE for their work tasks, OSHA's 29 CFR 1910.132 (d)(1) requires that employers perform a PPE assessment to determine whether hazards are present, or likely to be present, that necessitate the use of personal protective equipment. In addition, 29 CFR 1910.132 (d)(2) requires a written certification of the assessment.
Hierarchy of Controls
A systematic review of each work task is needed to identify potential hazards. Prior to requiring employees to wear PPE, however, the hierarchy of controls should be utilized to eliminate or reduce the existing hazard(s) to avoid the need for PPE. The hierarchy of controls states that hazards should be controlled in this preference:
1. Elimination
2. Substitution
3. Engineering Controls
4. Administrative Controls
5. Personal Protective Equipment
PPE should be selected only after the first four options have been evaluated and found to be infeasible.
Personal Protective Equipment for Various Exposures
Once the hazard assessment is complete, appropriate PPE must be selected. Listed below is a summary of typical PPE for various work tasks based upon National Safety Council, OSHA, and ANSI requirements and recommendations.
|
Work Task |
Typical Personal Protective Equipment |
|
Wire brush wheels |
Safety glasses with side shields or impact goggles |
|
Grinding stones |
Faceshield with either safety glasses and side shields or impact goggles |
|
Metalworking machines |
Safety glasses with side shields or impact goggles, barrier creams |
|
Compressed air |
Impact goggles or safety glasses with side shields |
|
Woodworking machines |
Abdominal guard or anti-kickback apron, impact goggles or safety glasses with side shields |
|
Handling wood, metal, glass, etc. |
Kevlar, leather gloves, or hand pads |
|
Landscaping tools |
Safety glasses with side shields |
|
Maintenance |
Breast pockets sewn closed or removed, tool belt with tools on side, gloves, safety harness and lanyard, impact goggles, or safety glasses with side shields |
|
Material handling |
Gloves, hard hat, eye protection |
|
Cold weather |
Hard hat liners |
|
Close quarters work |
Hard hats |
|
Falling objects |
Hard hats |
|
Sparks, hot metals |
Flame-resistant caps, aprons, hoods, Nomex® canvas spats |
|
Long hair protection |
Cool lightweight cap with long visor (hair under cap), and hair nets |
|
Acids, alkalis, etc.--splash hazard |
Large quantities: Acid suits, hoods. Small quantities: Faceshield and splash-proof goggles |
|
Limited direct splash from acids, alkalis, etc. |
Faceshield and chemical goggles |
|
Lifting 15-pound solid objects 1 foot or more at least once per day; rolling rolls of paper, steel, hogsheads |
Toe protection |
|
Chain saws |
Chaps, eye protection, hearing protection, hard hats |
|
Working in vicinity of flammable liquids handled at > autoignition temperature |
Flame-retardant clothing |
|
Sun exposure |
Wide-brim hats, long-sleeve clothing and/or sunscreen |
|
Working on energized electrical conductors > 50 volts |
Flame-retardant clothing and voltage-rated tools and gloves, based upon NFPA 70E flash hazard analysis and OSHA 1910.335 requirements |
Who Pays for PPE?
During training classes, I am routinely asked whether OSHA requires employers to pay for employee PPE. In an OSHA letter of Interpretation dated August 25, 2004, addressed to Brad Milleson of the Kellogg Company, OSHA states the following: "29 CFR 1910.132 requires employers to provide PPE and ensure its use. However, at the present time, OSHA does not view this section as imposing an enforceable obligation on employers to pay for PPE. Therefore, employees must be afforded the protection of PPE, regardless of who pays." OSHA has initiated rulemaking proceedings to clarify who is required to pay for required PPE.
It is important to note that there are numerous OSHA standards that specifically require the employer to provide PPE at no cost to the employee. Those standards include: Occupational Noise Exposure (1910.95); Respiratory Protection (1910.134); Permit-Required Confined Spaces (1910.146); Fire Brigades (1910.156); Logging Operations (1910.266); Asbestos (1910.1001); Inorganic Arsenic (1910.1018); Lead (1910.1025); Cadmium (1910.1027); Benzene (1910.1028); Bloodborne Pathogens (1910.1030); 1,2-dibromo-3-chloropropane (1910.1044); Acrylonitrile (1910.1045); Ethylene Oxide (1910.1047); Formaldehyde (1910.1048); Methylenedianiline (1910.1050); 1,3-Butadiene (1910.1051); and Methylene Chloride (1910.1052).
Apparel Policy
An apparel policy should be included in the PPE procedure. Loose clothing should be prohibited around rotating equipment, and long hair should be tucked under the collar or secured with a hair net. Rings, necklaces, and gloves should not be worn while working around rotating equipment because they may become entangled in the equipment.
Summary
Used properly, PPE provides a significant increase in protection for employees. The key components include a documented hazard assessment, employee training as well as periodic inspections to verify program effectiveness.
This article appeared in the December 2005 issue of Occupational Health & Safety.
This article originally appeared in the December 2005 issue of Occupational Health & Safety.